Supplemental Draft EIS Comments

We are private property owners on Wenniway Drive, approximately on half mile east of the South Launch Portal. We are completely in favor of building the Line 5 tunnel as soon as possible, without delay, as designed by the US Corp of Engineers. The new Line 5 Tunnel will be a significant risk mitigation to the transport of fuel through the Mackinaw Straights.

I do NOT want the Army Corps of Engineers to grant a permit to Enbridge for HDD drilling for the line 5 pipeline. There are multiple reasons why this alternative is senseless: fossil fuels are becoming increasingly unnecessary; Enbridge shows no talent for success with the HHD technique; the environmental impact on the Straits remains risky; Line Five supports a very small percentage of Michigan's fuel needs; and on and on.....
The best alternative is to decommission Line Five and remove it entirely from the Straits.
We all know it is the right thing to do. The safety of our life-saving water is the most important thing of all.
Do the right thing.

Although I write as a private individual, I am a researcher of the Great Lakes watershed and Director of The Freshwater Lab at the University of Illinois Chicago. At the time of the Enbridge Line 6b oil spill, my father worked as a radiologist at the VA Hospital in Battle Creek, Michigan where he treated many veterans exposed to oil during the rupture or during their contracted duties in clean-up. His accounts of illnesses with which our brave veterans contended as a result shocked me and led me to investigate the practices of the Canadian pipeline corporation.

Compliance with NEPA requires a reasonable range of alternatives. However, the alternative of decommissioning the Line 5 pipeline in the Straits of Mackinac, the position articulated by sovereign tribes in the region, the Governor of Michigan, and the Attorney General of Michigan remains absent in your analysis.

Instead, the possibility for horizontal directional drilling has arisen. Research into horizontal directional drilling suggests that its technical feasibility is largely theoretical, particularly in a geologically sensitive area like the Straits of Mackinac. Although an outcome of disruption to either Point Labarbe or McGulpin Point is preferable to disruptions at both locations, I request that USACE remove HDD possibilities in its analysis. Instead, an alternative of decommissioning pipelines in the straits should be considered.

We must amplify the concerns for Michigan groundwater, not to mention Lakes Michigan and Huron, to be exposed to HDD drilling fluids. With water quantity under duress nationally and internationally, few interests are served by risking these vital water bodies. In the case of such unparalleled water in a time of widespread drought, why would the United States risk its waters for reinforcement of a Canadian tar sands pipeline? It boggles the mind to read that a source water intake would be provided for a project opposed by Michigan voters.

Removal of wetlands and other coastal plants for this project would accelerate coastal erosion, already an issue in the area and remove the natural form of water filtration that such plants provide.

Rather than mitigation and minimization when Enbridge applied HDD in its installation of an enlarged Line 3 pipeline, we witnessed the puncture of four aquifers and negative impacts to Minnesota watersheds.

In 2018, the Minnesota Public Utilities Commission (PUC) unanimously approved the new route and size of Line 3. Enbridge had spent $11 million lobbying them, as well as other relevant agencies. Joined by the Minnesota Department of Commerce, indigenous and environmental groups appealed the decision. The Minnesota Court of Appeals found that Enbridge’s environmental impact statement lacked evaluation of how a spill would affect Lake Superior. After resubmitting the environmental impact statement, the Public Utilities Commission gave Enbridge the go-ahead in November 2020 with its independent commissioner posing vehement dissent. The next week, the U.S. Army Corps of Engineers gave the company a clean water permit.

In January 2021, toward the beginning of Enbridge’s HDD disemboweling for the trench, workers punctured an aquifer near the Clearbrook terminal. Enbridge neglected to report the breach, leaving the Minnesota Department of Natural Resources unaware of the damage until June 2021. After six months of steady water loss in a year where much of the country contended with drought, the DNR issued a $3.3 million fine with an order for Enbridge to stem the outflow.

One year following the rupture, the Canadian corporation finished patching the earth and claimed the groundwater damage was contained. A unique wetland system of fens is part of the watershed pierced while building a pipeline. For slicing the aquifer, Enbridge faced a misdemeanor for appropriating waters without permit.

The Minnesota Attorney General’s press release admits that the $1000 fine is “the only charge against Enbridge the State can support with probable cause under current state law” and, so long as Enbridge didn’t leak more groundwater in a year, the charges would be dismissed. The laying of Line 3 penetrated three more aquifers. The Minnesota Department of Natural Resources reported total losses of nearly 300 million gallons of groundwater. Surface water did not escape the peril of construction: drilling fluid leaked 28 times at 12 junctures where the pipeline crosses rivers. None of these accidents stopped construction or provoked reevaluation.

A lakebed is not solid and stable but rather punctuated by chasms and deposits of water and gas best envisioned as matching the intensity and variation of the currents in the Straits. As prelude to creation of the Mackinac Straits Corridor Authority and its pledge that the State of Michigan will assume responsibility for Enbridge’s tunnel, an engineering consulting company named Dynamic Risk Assessment Systems, Inc. considered its feasibility. The 337 page report entitled “Alternatives Analysis for the Straits Pipeline” hinges on five conditions that must be met for the tunnel to be safer than the existing pipes atop the lakebed. The conditions require investigation of lakebed geology, confirmation of “entirely sound and solid bedrock,” little risk of groundwater pressure, no presence of methane or toxic gas, and that the new stretch of pipeline be locked in place by filling the tunnel with concrete. The rock surfaced from the Straits, in turn, would enter waste streams.

Dynamic Risk’s conditions seem to have evaporated from consideration. What happened to these assessments and why did these concerns disappear from the permit extended in October 2025? Ironically, the gas and oil tunnel or enlarged pipeline would lie above local deposits of gas and oil, which could easily combust upon contact with a HDD machine or boring machine dipping 60 to 250 feet beneath the lakebed at a rate of 40 feet per day.

Horizontal drilling under Lake Michigan for the line 5 tunnel is a bad idea. The line 5 project is a bad idea by itself. We need to reduce the amount of fossil fuel usage in order to reduce the amount of greenhouse gases that are being created or we will lose all of our delicate ecosystems. This is also a threat to drinking water for all the surrounding lifeforms including humans. Please reject the line 5 proposal.

STOP LINE 5! ENBRIDGE ISNT IN COMPLIANCE AND POLLUTES OUR WATER AND SOIL

Subject: Oppose Enbridge Line 5 Drilling Under the Straits of Mackinac – Permit No. LRE-2010-00463-56-A19

Dear U.S. Army Corps of Engineers, Detroit District:

I am writing to strongly oppose Enbridge’s proposed Line 5 drilling plan under the Straits of Mackinac and to urge you to deny the requested permit, or at minimum reject the horizontal drilling option and fully evaluate a “no action” alternative that leads to decommissioning Line 5 in the Great Lakes.

The Straits of Mackinac are one of the worst possible locations for an oil pipeline project. Powerful and rapidly shifting currents mean that in the event of a failure, oil could spread quickly into both Lake Michigan and Lake Huron at the same time, threatening drinking water, fisheries, tourism, and coastal communities across an enormous area. The Great Lakes hold a significant share of the world’s surface freshwater and are simply not an appropriate place to gamble on another high-risk fossil fuel project.

Enbridge’s safety record alone should disqualify this proposal. In 2010, an Enbridge pipeline ruptured near Marshall, Michigan, sending more than 800,000 gallons of oil into Talmadge Creek and the Kalamazoo River—one of the largest and costliest inland oil spills in U.S. history. Cleanup dragged on for years, more than 1.2 million gallons of oil were ultimately recovered, and the company was cited for multiple safety violations and paid significant penalties.

It would be reckless to entrust the Straits of Mackinac and two Great Lakes to the same operator, using a technically complex horizontal drilling method beneath the lakebed.

I am also deeply concerned about the process. For years, the public was told this review focused on a concrete-lined tunnel proposal. Now the Corps has introduced a new drilling option—horizontal directional drilling under the Straits—late in the process and with limited public notice, despite the high level of public interest and the significant new risks this method poses.

This feels like a bait-and-switch that undermines public trust and the spirit of NEPA’s public participation requirements.

Any serious review must:

* Fully analyze a no-build / decommissioning alternative for Line 5 through the Straits, not just different ways to keep the oil flowing.

* Consider worst-case spill scenarios in the Straits, including winter conditions, ice cover, and the difficulty of containing and cleaning submerged oil in deep, fast-moving waters.

* Evaluate cumulative climate impacts, including upstream and downstream greenhouse gas emissions, and whether continuing Line 5 is compatible with state, federal, and tribal climate commitments.

* Respect tribal treaty rights and fully incorporate Indigenous concerns about fishing, cultural resources, and long-term stewardship of the Great Lakes.

* Require enforceable financial assurances from Enbridge that cover a worst-case spill and long-term restoration, so taxpayers are never left paying for corporate negligence.

Right now, the proposed drilling plan does the opposite of what we should be doing: it extends the life of an aging oil pipeline in one of the most sensitive and globally important freshwater ecosystems on Earth, for the benefit of a private company that already has a documented history of catastrophic failure.

For all of these reasons, I urge the Army Corps to reject the Line 5 drilling plan under the Straits of Mackinac, thoroughly evaluate a decommissioning alternative, and prioritize the protection of the Great Lakes, tribal rights, public safety, and the climate over the short-term interests of Enbridge.

Thank you for considering my comment.

Sincerely,

Ishanee DeVas
Chicago, IL

I am a retired Professional Engineer with 52 years of experience in consulting engineering and construction management for heavy civil projects, including dams, tunnels, water conveyance, hydroelectric power, highways, and navigation projects, and including associated environmental impacts and mitigation. I oppose the proposed pipeline installation under the waterways of the Great Lakes system by anyone, based on the potential downside risks of pollution of the proximate surface and underground water resources. I particularly oppose any such new projects by Enbridge which has a consistent track record of incompetence in its building, operation and maintenance of its similar projects. I urge USACE to deny this Applicant’s permit request.

Gene J Kocian, PE (retired)

To the U.S. Army Corps of Engineers, Detroit District:

Thank you for the opportunity to comment on the Supplemental Draft Environmental Impact Statement (EIS) for the Enbridge Line 5 Tunnel Project, specifically the horizontal directional drilling (HDD) Installation Alternative under the Straits of Mackinac.

My name is Maria, and I am a Midwestern resident who cares deeply about the Great Lakes as a source of drinking water, regional climate stability, recreation, and economic life for millions of people. I am writing to express my strong opposition to the proposed HDD drilling plan under the Straits and to urge the Corps to deny any permit that allows continued or expanded operation of Line 5 in this location.

1. The Straits are the worst possible place for an oil spill

The Straits of Mackinac are a uniquely high-risk location: powerful, reversing currents can carry oil quickly into both Lake Michigan and Lake Huron, turning a single failure into a binational catastrophe. University of Michigan modeling has shown that an oil release in the Straits could contaminate more than 700 miles of shoreline in Lakes Michigan and Huron, with visible oil potentially affecting thousands of square miles of open water.

Any drilling or pipeline project under this waterway must be held to the very highest standard of caution. Instead, the HDD alternative adds another layer of risk: geologic uncertainty, potential for drilling mud “frac-outs” into the lakebed, and the possibility of undetected failures in a location where cleanup would be extraordinarily difficult, especially under ice and in high-current conditions.

2. Enbridge’s safety record does not justify additional trust

The Supplemental Draft EIS must grapple honestly with the operator’s history. Enbridge has been responsible for some of the largest and most costly inland oil spills in U.S. history, including the 2010 Kalamazoo River disaster, where more than 840,000 gallons of oil were released, and cleanup took years.

As recently as November 2024, an Enbridge pipeline in Wisconsin leaked roughly 70,000 gallons of crude oil due to equipment failure, with evidence that the line may have been leaking for an extended period before discovery.

This is not an isolated incident—it is part of a pattern that should make regulators extremely cautious about accepting company assurances of safety.

Given this record, it is not sufficient for the Corps to “assume compliance” with laws and permits. The EIS must evaluate the realistic risk of equipment failure, human error, delayed detection, and inadequate response, and must weigh that risk against the irreplaceable value of the Great Lakes.

3. The HDD alternative was previously rejected as infeasible

The Corps’ own May 2025 Draft EIS treated the HDD option as infeasible based on Enbridge’s 2018 report. Now, Enbridge claims that technological advances have suddenly made this approach feasible and safe. That reversal looks, to many of us, like a “bait-and-switch”—especially after years of public discussion focused on a tunnel.

The Corps should not rely primarily on applicant-supplied studies to reverse its earlier conclusion. Any claim of new feasibility must be independently validated by neutral experts, with full public transparency about geologic data, drilling risks, and worst-case failure scenarios specific to HDD in this location.

4. The EIS must fully consider the No Action/decommissioning alternative

The purpose of NEPA is not to pick among only the company’s preferred construction techniques; it is to evaluate whether the project should proceed at all in light of its impacts and alternatives.

Given:

* The extreme sensitivity of the Straits

* The documented potential for a spill to impact hundreds of miles of shoreline and critical drinking-water, fishing, and recreation economies

* Enbridge’s history of major spills and delayed detection

The Final EIS must rigorously evaluate a No Action alternative that phases out Line 5 at the Straits, along with non-pipeline energy and transportation options. Continuing to invest in multi-decade oil infrastructure under the Great Lakes also has significant climate implications that affect public health and long-term regional stability.

5. Protecting the Great Lakes is in the public interest

The Great Lakes hold roughly 20% of the world’s fresh surface water and about 95% of the United States’ fresh surface water supply.
GTB of Ottawa and Chippewa Indians. These waters are not just a route for private profit; they are a public trust that supports drinking water, fisheries, tourism, and the cultural and treaty rights of Indigenous nations.

Under that public-interest standard, the risk of a catastrophic spill from Line 5—whether from the existing lines or a new HDD installation—is simply unacceptable.

For these reasons, I respectfully urge the Army Corps of Engineers to:

* Reject the HDD Installation Alternative and deny the permit for new drilling under the Straits of Mackinac;

* Conduct a truly robust analysis of the No Action / decommissioning alternative for Line 5 at the Straits; and

* Ensure that the Final EIS fully incorporates independent spill-risk modeling, Enbridge’s complete safety record, treaty and environmental justice considerations, and climate impacts.

Thank you for your consideration of my comments and for your work to protect the Great Lakes and the communities that depend on them.

Sincerely,
~ Maria T.
Davenport, Iowa

Of all the dumbest ideas... Why not funnel the sludge right to every Great Lakes-siphoning AI data center and celebrate by serving cookies baked with flour cut with asbestos?